Attachment to Annual 47 C.F.R. 64.

2009(e) CPNI Compliance Certification

EB Docket No. 06-36
Statement Regarding CPNI Operating Procedures
The CPNI Operating Procedures of WaveDivision Holdings, LLC (Wave) on behalf Wave subsidiaries
and telecommunications carriers WaveDivision I, LLC, WaveDivision II, LLC, WaveDivision III, LLC, Cedar
Communications, LLC, WaveDivision IV, LLC, Wave/Powers Acquisition, LLC, Astound Broadband, LLC and
WaveDivision VII, LLC (collectively, the Wave Subsidiaries), ensure that Wave and the Wave Subsidiaries are
and will be in compliance with 47 U.S.C. 222 and the rules contained in Title 47, Chapter 1, Subchapter B. Part 64,
Subpart U of the Code of Federal Regulations, 47 C.F.R. 64.2001 et seq. of the commissions rules. All of Waves
CPNI Operating Procedures are the Operating Procedures of any and all Wave Subsidiaries. Included among the
provisions of Waves CPNI Operating Procedures are:

A requirement that Wave have at all times a CPNI Compliance Officer to supervise the
implementation of Waves CPNI Operating Procedures.

Detailed procedures for safeguarding CPNI, including procedures for customer authentication and
password protection of CPNI, in compliance with 64.2010.

Detailed procedures for determining what type of customer approval is necessary for use,
disclosure and access to CPNI, in compliance with 64.2007. In those instances in which
customer approval is required for use of CPNI, Wave obtains approval through verbal, written, or
electronic methods in compliance with 64.2007.

Detailed procedures for obtaining opt-out and opt-in approval from customers. For one-time use
of CPNI on inbound and outbound customer telephone contacts for the duration of the call, Wave
representatives obtain verbal consent from the customer pursuant to the Commissions rules.

A requirement that the billing system records for customers accounts allow the status of
customers CPNI approval to be easily ascertained prior to the use of CPNI, in compliance with
64.2009.

A requirement for supervisory approval for all outbound marketing campaigns, including
determination of any customer approval requirements for the campaigns, in compliance with
64.2009.

A requirement that personnel be trained to identify what customer information is CPNI, as defined
in 64.2003, and that personnel be trained as to when they are and are not authorized to use
CPNI, in compliance with 64.2009.

A written disciplinary process for misuse of CPNI, in compliance with 64.2009.

Detailed filing, notice and recordkeeping requirements.

Detailed procedures to be followed in the event of a breach of CPNI, in compliance with

64.2011.

Wave and the Wave Subsidiaries were not required to take action against any data brokers in 2014, nor did
Wave or any of the Wave Subsidiaries receive any customer complaints based on unauthorized release of CPNI in
2014.